ML20196H770
| ML20196H770 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 07/24/1997 |
| From: | Kraft E COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-254-96-17, 50-265-96-17, ESK-97-151, NUDOCS 9708010019 | |
| Download: ML20196H770 (4) | |
Text
_ _
( onuminweahh I dison O)mp.un Quad Citics Generating Nation
- 22'IO 206th Asenue North Lordova. H. 6l 2 62 CiO l
ei.umis+22 ii ESK-97-151 July 24,1997
)
U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention:
Document Control Desk
Subject:
Quad Cities Station Units 1 and 2; NRC Docket Numbers 50-254 and 50-265:
NRC Inspection Report Numbers 50-254/96-017 and 50-265/96-017
Reference:
(a)
J. A. Grobe Letter to E. S. Kraft, Jr. dated February 4,1997.
l (b)
A. B. Beach Letter to E. S. Kraft, Jr. dated June 24,1997.
l Enclosed is Commonwealth Edison's (Comed's) response to the Notices of Violation (NOV) transmitted in reference (b). The NOV cited two Severity Level IV violations. The first concerned the system being inoperable because the required 2 1/8 inch water gauge positive pressure between the control room and adjacent areas did not exist from September 24,1996 to November 3,1996 as required by section 6.4.4.1 of the UFSAR. The second violation concerned the failure of the test program to verify that the control room emergency ventilation system could maintain the 21/8 inch water gauge positive pressure that was specified in section 6.4.4.1 of the UFSAR since the system was modified in 1985.
This letter contains no new commitments.
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r U. S. NRC ESK-97-151 2
July 24,1997 t
If there are any questions or comments concerning this letter, please refer them to Mr. Charles Peterson, Regulatory Affairs Manager, at (309) 654-2241, extension
'3609.
Respectfully,
'(L L L N
. S. Kraft, Jr.
l Site Vice President l
Quad Cities Station Attachment (A)" Response to Notice of Violation" i
l cc:
A. B. Beach, Regional Administrator, Region III R. M. Pulsifer, Project Manager, NRR C. G. Miller, Senior Resident Inspector, Quad Cities i
W. D. Leech, MidAmerican Energy Company i
D. C. Tubbs, MidAmerican Energy Company F. A. Spangenberg, Regulatory Affairs Manager, Dresden INPO Records Center Office of Nuclear Facility Safety, IDNS DCD License.(both electronic and hard copies)
M. E. Wagner, Licensing, Comed d
1 i
i
'4 ATTACHMENT A
)
" Response to Notice of Violation" ESK-97-151 Page 1 of 2 NOTICE OF VIOLATION (50-254-96-017-10) l Technical Specification 3.8.D requires operability of the control room emergency ventilation system while the plant is in Modes 1,2, or 3.
Section 6.4.4.1, ' Control Room Radiation Protection' of the USAR stated a positive pressure of 21/8 inch water gauge is maintained between the control room emergency zone and adjacent areas.
Contrary to the above, between September 24,1996 (the date that Technical Specification 3.8.D was implemented), and November 3,1996, while both Units 1 and 2 were in Mode 1, the control room emergency filtration system was inoperable because the required 21/8 inch water gauge positive pressure between the control room and adjacent areas -- as stated section 6.4.4.1 ofin USAR -- did not exist.
i Reasons for the Violation:
1 Comed acknowledges the violation. The reason for the Technical Specification nonconformance was an inadequate technical review by the Quad Cities Technical Specification Upgrade Project l
(TSUP) implementation team.
Corrective Actions Taken:
Performed repairs and successfully completed testing which verified that the control room was e
being maintained at the required positive pressure of 1/8 inch w.g. per Technical Specifications.
Revised surveillance procedures to conform with the specification to measure control room pressure in relation to adjacent areas.
Initiated and completed a subsequent review of surveillances associated with the Upgraded Technical Specifications. No additional nuased Technical Specifications were identified.
Needed surveillance procedure enhancement ; were identified and corrected.
Corrective Actions to Prevent further occurrences:
No further actions are required.
Date when full compliance will he met:
c Full compliance was met with the successful completion of a Technical Specification Surveillance Test on November 3,1996
)
ATTACHMENT A
" Response to Notice of Violatio'n" ESK-97-151 Page 2 of 2 i
i NOTICE OF VIOLATION (50-254-96-017-11) i 10 CFR Part 50, Appendix B, Criterion XI, ' Test Control' requires, in part, that a test program be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.
Section 6.4.4.1, ' Control Room Radiation Protection' of the US AR stated a positive pressure of 21/8 inch water gauge is maintained between the control room emergency zone and adjacent areas.
Contrary to the above, since the control room emergency filtration system was modified in 1985, the test program of the control room emergency ventilation system failed to verify that the control room emergency ventilation system could maintain the 21/8 inch water gauge positive pressure specified in section 6.4.4.1 ofin USAR.
i Reasons for the Violation:
Comed acknowledges the violation. The reasons for the event were:
the modification test procedure was less than adequate e
the lack of a rigorous modification process and review in 1985, e
inadequate development of the modification test.
e Corrective Actions Taken:
l Revised and standardized implementing procedures for design change process. Specifically, l
e procedures addressing design change acceptance criteria testing and guidance for establishmg post modification testing were revised.
An Engineering Assurance Group has been established on an interim basis to provide l
e additional oversight of key engineering activities to ensure conformance to design basis including modification test reviews.
Corrective Actions to Prevent further occurrences:
No furthe actions are required.
Date w! en full compliance will be met:
Full c<. mpliance was met with the restoration of CREVs train 'B' to full conformance on May. 1997.
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